PRIVACY POLICY

This privacy policy, describes how MANY TOUCHES JOINT STOCK COMPANY ("Many Touches", "we", "us" or "our") we collect, use ("proceed") your information when you use our products, services ("Services")

This privacy policy does not apply to any products, services, websites, or content provided by third parties or that utilize separate privacy policies.

I. GENERAL REGULATION
a) "Personal Data": refers to information in the form of symbols, writing, numbers, images, sound, or similar forms in the electronic environment that is associated with a specific individual or helps identify a specific individual, as specifically defined in Section 2 regarding the types of information we collect.
b) "Subject of Personal Data": an individual reflected by Personal Data, including all individuals – customers, individuals using our products or services, Many Touches employees, shareholders, and/or other individuals with legal relationships arising with us.
c) In the scope of processing personal data under this Policy, Many Touches is the controller and/or the controller and processor of Personal Data.
d) Processing of personal data involves one or more activities affecting personal data, such as: collection, recording, analysis, verification, storage, modification, disclosure, combination, access, retrieval, erasure, encryption, decryption, copying, sharing, transmission, provision, transfer, deletion, destruction of personal data, or other related actions.
e) By registering to use, using Many Touches' products or services; checking the consent box, notifications; entering into contracts and/or allowing Many Touches to process Personal Data, the Subject of Personal Data fully accepts and unconditionally agrees to all the terms and conditions of the policies referenced in this Policy and any changes (if any) made during each period.
II. TYPES OF PERSONAL DATA WE COLLECT AND PROCESS
1. Basic Personal Data includes:
  • a) Your first name, middle name, and last name or any other aliases;
  • b) Date of birth, date of death, or missing date;
  • c) Gender;
  • d) Place of birth, place of registration, permanent residence, temporary residence, current address, hometown, contact address;
  • e) Nationality;
  • f) Information about your The Ring (for example, The Ring's ID number);
  • g) Images of the individual;
  • h) Phone number, ID card number, personal identification number, passport number, driver's license number, vehicle registration number, personal tax identification number, social insurance number, health insurance card number;
  • i) Marital status;
  • j) Information about family relationships (parents, children);
  • k) Information about the individual's account numbers; personal data reflecting online activities, internet history;
  • l) Other information related to a specific individual or helping identify a specific individual;
  • m) Information collected automatically when the Subject of Personal Data uses Many Touches' website, mobile applications, and other communication tools, such as IP address, cookies, device IDs, and accessed information sources.
2. Sensitive Personal Data includes:
  • a) Information about physical attributes, personal biological characteristics;
  • b) Customer information of credit institutions, foreign bank branches, authorized intermediary payment service organizations, including: customer identification information as required by law, account information, deposit information, property deposit information, transaction information, information about the organization or individual acting as collateral at a credit institution, bank branch, organization providing intermediary payment services;
  • c) Location data of the individual determined through location-based services;
  • d) Other personal data specified by law as special and requiring necessary security measures.
III. PURPOSES AND METHODS OF MANY TOUCHES' COLLECTION AND PROCESSING OF PERSONAL DATA
1. We collect and process your Personal Data for one or more of the following purposes:
  • a) Identifying, verifying, and maintaining accurate information about the Subject of Personal Data (KYC) and other checks with the Data Subject upon request;
  • b) Assessing, determining, evaluating, and approving the provision of products, services based on the registration documents, proposals of the Subject of Personal Data and/or related parties of the Subject of Personal Data;
  • c) Assessing, constructing, and evaluating the reliability of the Subject of Personal Data's use of products and services;
  • d) Considering providing or continuing to provide any products, services of Many Touches with the Subject of Personal Data;
  • e) Fulfilling obligations under contracts, agreements, and providing products, services to the Subject of Personal Data;
  • f) Customer care, resolving complaints, lawsuits of the Subject of Personal Data;
  • g) Contacting the Subject of Personal Data, directly marketing, indirectly marketing products, services to the Subject of Personal Data, implementing promotional programs, exchanges, rewards, gift giving;
  • h) Understanding the current and future needs of the Subject of Personal Data;
  • i) Improving, enhancing, personalizing, individualizing Many Touches' products and services, and developing new products, services;
  • j) Conducting market research, surveys, and analyzing data related to any products, services offered by Many Touches to the Subject of Personal Data;
  • k) Monitoring, ensuring the safety of transactions, providing timely customer support in emergency situations.
  • l) Performing other activities related to the provision, operation, and management of Many Touches' products, services, and/or to develop, improve, and enhance the provision of Many Touches' products, services to Subject of Personal Data in general; and other purposes that Many Touches deems appropriate at various times.
  • m) To ensure Many Touches' legitimate business purposes in cases deemed necessary by Many Touches, including but not limited to exchanging information with Many Touches' partners, service providers for Many Touches.
  • n) To input, to check the completeness and accuracy of the data that the Subject of Personal Data provides to Many Touches and/or the information Many Touches inputs into the system;
  • o) To comply with agreements, contracts between Many Touches and other third parties;
  • p) To fulfill reporting, financial, accounting, and tax obligations;
  • q) To perform activities for audit, risk management, and compliance purposes;
  • r) To meet the internal operational needs of Many Touches or its subsidiaries;
  • s) To provide to competent state authorities as required by law;
  • t) To fulfill obligations under the law, international agreements that Many Touches must comply with, and requirements of competent state authorities;
  • u) To detect, prevent, and investigate crimes, attacks, or violations, including fraud, money laundering, terrorism, mass destruction weapons sponsorship, bribery, corruption, or tax evasion.
  • v) Ensure the legal rights and interests of Many Touches and the social community.
  • w) To protect or enforce the legal rights and interests of Many Touches, including the right to collect fees, recover and process debts owed by the Subject of Personal Data to Many Touches;
  • x) To fulfill responsibilities to the community, society;
  • y) Facilitate mergers, acquisitions, and divestitures of Many Touches;
  • z) To perform transactions such as transfer, disposal, merger, or acquisition involving the operations, assets of Many Touches.
2. In the case of processing Personal Data for purposes other than those mentioned above, Many Touches will only do so in agreement with the Subject of Personal Data or with the consent of the Subject of Personal Data.
3. Provision of Personal Data: In order to carry out the purposes and activities of processing Personal Data in this Policy, Many Touches may provide Personal Data to the following parties:
  • a) Many Touches' subsidiaries: any subsidiaries of Many Touches such as subsidiaries, joint ventures, affiliates determined by Many Touches from time to time.
  • b) Third parties assisting in verifying Subject of Personal Data information: including banks, credit organizations that Many Touches is cooperating with, legal entities owning, managing buildings
  • c) Competent state authorities: Authorities requiring information according to legal regulations; Any court, arbitration, litigation agency, enforcement agency authorized/required to enforce responsibilities from Many Touches; Any individual, competent authority, or managing authority or third party that Many Touches is allowed or required to disclose according to the regulations of any country or any other contract or commitment between the third party and Many Touches.
  • d) Service providers for Many Touches and cooperating service providers with Many Touches: Business partners, related partners collaborating with Many Touches to develop, provide, or relate to the development, provision of Many Touches' products, services.
  • e) Third parties authorized by the Subject of Personal Data: Anyone notified, authorized, permitted by the Subject of Personal Data to provide transaction information on behalf of the Subject of Personal Data.
  • f) Other third parties: Other relevant parties that Many Touches deems necessary to meet, protect the legal rights and interests of the Subject of Personal Data; Advisors to the Subject of Personal Data or Many Touches including accountants, auditors, lawyers, financial advisors; Other Personal Data Processing parties performed with the consent of the Subject of Personal Data;
4. Personal Data Processing Methods: Depending on the purpose of Personal Data processing, Many Touches or Many Touches' data processing party or third party authorized to process data for Many Touches may apply appropriate processing methods, including but not limited to automated, manual or other processing methods in compliance with the legal regulations and Many Touches' regulations from time to time.
5. Personal Data Processing Period: Depending on the specific operation, Personal Data may be processed by Many Touches after being provided, collected and terminated when the data processing is completed in accordance with the intended purpose or until the Personal Data is deleted as regulated.
6. Unintended Consequences, Damages: The processing of Personal Data always carries the risk of data leakage or inappropriate data processing. Many Touches recognizes the importance and responsibility of protecting Personal Data, committing to apply appropriate protection measures according to current legal regulations, and regularly reviewing, updating the best technical measures to ensure safety in Personal Data processing, making maximum efforts to prevent risks and limit unintended consequences, damages that may occur, protecting the legal rights and interests of the Subject of Personal Data and Many Touches.
7. In addition, in the following cases, Many Touches is allowed to process Personal Data without the consent of the Subject of Personal Data:
  • a) Emergency cases, the immediate processing of relevant personal data to protect the life, health of the data subject or others
  • b) Publicizing personal data as prescribed by law.
  • c) Processing the data of state agencies with jurisdiction in cases of urgent situations regarding national defense, national security, social order and safety, major disasters, dangerous epidemics; when there is a risk of threatening security, defense but has not reached the level of declaring a state of emergency; prevention, control of riots, terrorism, prevention, and control of crime and law violations according to legal regulations.
  • d) To fulfill the obligations under the contract of the data subject with relevant agencies, organizations, individuals according to the law.
  • e) Serving the operations of state agencies as regulated by specialized laws.
IV. TRANSFER OF PERSONAL DATA ABROAD
In order to fulfill the purposes of processing Personal Data outlined in this Policy and the contracts, agreements, and other documents established with the Subject of Personal Data, we may need to provide/transfer Personal Data to relevant third parties of Many Touches, and these third parties may be located within or outside the territory of Vietnam. When performing the provision/transfer of Personal Data abroad (including but not limited to activities using network space, devices, electronic means, or other forms to transfer Personal Data outside the territory of Vietnam), we will request the receiving third party to ensure the safety and security of the provided/transferred Personal Data. We commit to fully comply with the regulations, compliance requirements of Vietnamese law to ensure the safety of Personal Data.
V. RIGHT OF THE SUBJECT OF PERSONAL DATA
1. We respect and strive to protect the following rights of the Subject of Personal Data:
  • a) Right to be informed;
  • b) Right to consent;
  • c) Right to access (including view, edit, or request edits to Personal Data);
  • d) Right to withdraw consent;
  • e) Right to erasure of data;
  • f) Right to restrict data processing;
  • g) Right to data portability;
  • h) Right to object to data processing;
  • i) Right to lodge complaints, accusations, lawsuits;
  • j) Right to request compensation for damages;
  • k) Right to self-defense.
2. We will process the requests of the Subject of Personal Data in accordance with legal regulations and consider the legitimate rights and interests of the Subject of Personal Data. However, in the event that the Subject of Personal Data withdraws their consent, requests data deletion, and/or exercises related rights concerning any or all Personal Data that may affect Many Touches' ability to provide/maintain products and services to the Subject of Personal Data, depending on the nature of the Subject of Personal Data's request, we may review and decide not to continue providing Many Touches' products and services to the Subject of Personal Data. The actions taken by the Subject of Personal Data under this provision will be considered a unilateral termination by the Subject of Personal Data of any relationship between the Subject of Personal Data and Many Touches, and may result in a violation of obligations or commitments under the contract between the Subject of Personal Data and Many Touches. Additionally, we reserve our rights and lawful remedies in such cases. Accordingly, Many Touches will not be liable to the Subject of Personal Data for any losses incurred, and the legal rights of Many Touches will be clearly reserved for limiting, restricting, suspending, canceling, or obstructing that Personal Data.
3. For security purposes, the Subject of Personal Data may need to make their requests in writing or use other methods to prove and verify their identity. Many Touches may require the Subject of Personal Data to verify their identity before processing their requests.
4. To clarify, we have the right to refuse to fulfill the requests of the Subject of Personal Data in certain cases, including but not limited to cases where: (i) the Subject of Personal Data does not follow the procedures and procedures instructed by us; (ii) the Subject of Personal Data does not provide or provides insufficient documents, materials to verify their identity; or (iii) in cases where Many Touches assesses signs of fraud, violations of Personal Data protection; or (iv) legal regulations do not allow the fulfillment of the Subject of Personal Data's request.
VI. OBLIGATION OF THE SUBJECT OF PERSONAL DATA
1. Protect your Personal Data: Request relevant organizations and individuals to protect your Personal Data.
2. Respect and protect others' Personal Data.
3. Provide complete and accurate personal data when consenting to the processing of Personal Data.
4. Participate in spreading awareness and promoting skills in protecting Personal Data.
5. Follow legal regulations on Personal Data protection and actively participate in preventing and combating any violations of the regulations on Personal Data protection.
6. Immediately notify us if you discover or suspect that your Personal Data has been disclosed, leading to risks in using services, or any violations of Personal Data protection as outlined in this Policy that the Personal Data Subject can identify.
7. Regularly check the official electronic information page of Many Touches to stay updated and comply with any changes (if any) related to the Personal Data protection policy in this Policy.
8. Fulfill other obligations as stipulated by law.
VII. PERSONAL DATA STORAGE
Personal Data will be stored by Many Touches, and appropriate measures will be applied for security. Within the legal framework, Many Touches may store Personal Data in Vietnam or abroad, including cloud-based storage solutions. The storage of Personal Data is carried out for the necessary duration to fulfill the purposes agreed upon with the Personal Data Subject in this Policy, contracts, agreements, and other documents established with the Personal Data Subject, except in cases where storage is required or mandated for a longer period by legal regulations at different times.
VIII. PROCESSING PERSONAL DATA OF INDIVIDUALS UNDER 18 YEARS OLD
We do not intend to collect data from individuals under 18 years of age or market to them. By using the Service, you commit that you are 18 years of age or older, or a parent or guardian of an underage person, and agree to allow the underage person to use our products and services. If we discover that personal information from users under 18 years of age has been collected, we will deactivate the account and take reasonable measures to delete the data from our records. If you become aware of any information, we collect that may be from children under 18 years of age, please contact us at contact@manytouches.com.
IX. CONTACT
In case the Data Subject has any questions related to this Policy, please contact Many Touches via email or the hotline number below:
  • Email: contact@manytouches.com.
  • Hotline: 1800 556 841